ML15118A317

Notice of Violation from Insp on 980726-0905.Violation Noted:On 980522,licensee Made Changes to Facility as Described in FSAR Without Adequate Written Safety Evaluation Providing Basis That Change Did Not Involve Safety Question

ML15118A317
Person / Time
Site:	Oconee
Issue date:	10/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML15118A316	List: ML15118A315 ML15118A317
References
50-269-98-08, 50-269-98-8, 50-270-98-08, 50-270-98-8, 50-287-98-08, 50-287-98-8, NUDOCS 9810290273
Download: ML15118A317 (2)

Text

NOTICE OF VIOLATION Duke Energy Corporation Docket Nos. 50-269. 270, and 287 Oconee 1, 2, and 3 License Nos. DPR-38. 47, and 55 During an NRC inspection conducted on August 24 - September 4, 1998, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, Rev. 1. the violation is listed below:

10 CFR 50.59 (a)(1) allows the holder of a license to make changes to the facility and procedures as described in the Final Safety Analysis Report without prior Commission approval unless the proposed change involves a change in the Technical Specifications or an unreviewed safety question. 10 CFR 50.59(b)(1) requires that the licensee shall maintain records of changes to the facility and that these records include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.

Final Safety Analysis Report Table 6-1. Net Positive Suction Head Available to Engineered Safeguards Pumps During Recirculation, dated December 31, 1991.

specified that adequate net positive suction head was available to the Reactor Building spray pumps without crediting containment over pressure.

Contrary to the above, on May 22, 1996. the licensee made changes to the facility as described in the Final Safety Analysis Report without an adequate written safety evaluation providing the basis for the determination that the change did not involve an unreviewed safety question. In the 1996 Final Safety Analysis Report revision, the licensee deleted Table 6-1 based on an analysis of 1991 and 1992 which determined that Reactor Building over pressure was required to assure operability of the Reactor Building spray pumps during the design basis accident. This was inconsistent with the NRC.reviewed and approved licensing basis documented in the Safety Evaluation Report, dated July 6, 1973, and Final Safety Analysis Report Table 6-1, which specified that Reactor Building over pressure was not required to assure Reactor Building spray pump net positive suction head requirements were met. The licensee's 50.59 safety evaluation, dated May 22. 1996, for the 1996 revision of the Final Safety Analysis Report, was inadequate in that it failed to identify that this revised Reactor Building spray pump net positive suction head requirement increased the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the Safety Analysis Report.

This is a Severity Level IV Violation (Supplement I).

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in Licensee Event Report 50-269/98-11, 9810290273 981005 PDR ADOCK 05000269 Q

PDR

Notice of Violation 2

Available Net Positive Suction Head for Reactor Building Spray Pumps Outside Design Basis Due to Incorrect Interpretation, dated September 17. 1998.

However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the US Nuclear Regulatory Commission, ATTN:

Document control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region II. and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

Dated at Atlanta, Georgia this 5th day of October, 1998